2025 Tariffs
OCEANAIR has compiled data from the Federal Register regarding tariffs enacted under the Trump Administration. Our goal is to maintain and update this information to better assist our clients in reviewing applicable tariffs based on their countries of origin and commodities. Where relevant, we provide links to detailed lists for further reference.
De Minimis: Each tariff-impacting Executive Order has aimed to limit de minimis treatment, subjecting entries valued under $800 to the same supplemental tariff programs as formal entries. Given the significant volume affected, the administration has suspended these changes until the Secretary of Commerce confirms that “adequate systems are in place to fully and expediently process and collect tariff revenue.”
(last updated 04/11/2025)
Date Implemented | Program | HTS | Percent | Countr(ies) | Description | Exclusions | Links |
4/10/2025 | Reciprocal | 9903.01.63 | 125% | CN | Articles originating from China, including Hong Kong and Macau, will be subject to an additional ad valorem duty rate of 125%. | • Annex II HTS • Goods with 20%+ U.S. content • Goods subject to Section 232 tariffs • USMCA-qualified goods • Donations for human suffering relief and informational materials • Goods in transit prior to the effective date, subject to conditions | |
4/9/2025 | Reciprocal | 9903.01.63 | 84% | CN | Articles originating from China, including Hong Kong and Macau, will be subject to an additional ad valorem duty rate of 84%. | • Annex II HTS • Goods with 20%+ U.S. content • Goods subject to Section 232 tariffs • USMCA-qualified goods • Donations for human suffering relief and informational materials • Goods in transit prior to the effective date, subject to conditions | |
4/5/2025 | Reciprocal | 9903.01.63 | 34% | CN | Articles originating from China, including Hong Kong and Macau, will be subject to an additional ad valorem duty rate of 34%. | • Annex II HTS • Goods with 20%+ U.S. content • Goods subject to Section 232 tariffs • USMCA-qualified goods • Donations for human suffering relief and informational materials • Goods in transit prior to the effective date, subject to conditions | |
4/5/2025 | Reciprocal | By Country | Varied | All Outside China | As of April, the country-specific ad valorem duty rate has been paused. | • Annex II HTS • Goods with 20%+ U.S. content • Goods subject to Section 232 tariffs • USMCA-qualified goods • Donations for human suffering relief and informational materials • Goods in transit prior to the effective date, subject to conditions | |
4/5/2025 | Reciprocal | 9903.01.25 | 10% | All Outside China | Articles originating outside of China, including Hong Kong and Macau, will be subject to an additional ad valorem duty rate of 10%. | • Annex II HTS • Goods with 20%+ U.S. content • Goods subject to Section 232 tariffs • USMCA-qualified goods • Donations for human suffering relief and informational materials • Goods in transit prior to the effective date, subject to conditions | |
3/12/2025 | Section 232 | 9903.81.87 | 25% | ALL | Iron or steel products including flat-rolled products, bars and rods, wire, sheet piling, rails, tubes, pipes, hollow profiles, ingots, and certain stainless steel products (refer to the provided link for specific HTS classifications). | There is no exclusion application process available at this time. | |
3/12/2025 | Section 232 | 9903.81.88 | 25% | ALL | FTZ-specific transactions completed prior to March 12. | There is no exclusion application process available at this time. | |
3/12/2025 | Section 232 | 9903.81.89 | 25% | ALL | Derivative iron or steel products, including nails, tacks, staples, bumper stampings for motor vehicles, and body stampings for tractors (refer to the provided link for specific HTS classifications). | There is no exclusion application process available at this time. | |
3/12/2025 | Section 232 | 9903.81.90 | 25% | ALL | Derivative iron or steel products, inclusive of fittings, wire, fencing, chains, springs, radiators, select tableware, kitchenware, and other household articles, sinks, bathtubs, horseshoes, and items classified under tariff 7326.90.8688 for miscellaneous steel articles without a specifically identified HTS code (refer to the provided link for specific classifications). | There is no exclusion application process available at this time. | |
3/12/2025 | Section 232 | 9903.81.91 | 25% | ALL | Derivative iron or steel products, including certain parts of machinery, agricultural equipment, and specific furniture and light parts (refer to the provided link for specific HTS classifications). | There is no exclusion application process available at this time. | |
3/12/2025 | Section 232 | 9903.81.92 | 25% | ALL | Summary of 9903.81.90 and 9903.81.91, where the melt and pour processes occur in the United States. | There is no exclusion application process available at this time. | |
3/12/2025 | Section 232 | 9903.81.93 | 25% | ALL | FTZ-specific transactions completed prior to March 12. | There is no exclusion application process available at this time. | |
3/12/2025 | Section 232 | 9903.85.02 | 25% | ALL | Aluminum products, including unwrought aluminum, bars, rods, profiles, wire, plates, foil, tubes, pipes, tube and pipe fittings, as well as castings and forgings (refer to the provided link for specific HTS classifications). | There is no exclusion application process available at this time. | |
3/12/2025 | Section 232 | 9903.85.04 | 25% | ALL | Derivative aluminum products, including stranded wire, cables with fittings or electrical conductors, motor vehicle bumper stampings, and body stampings for tractors (refer to the provided link for specific HTS classifications). | There is no exclusion application process available at this time. | |
3/12/2025 | Section 232 | 9903.85.04 | 25% | ALL | Derivative aluminum products, including doors, certain cooking and kitchenware, and miscellaneous articles not specified under 7619.99.5190 (refer to the provided link for specific HTS classifications). | There is no exclusion application process available at this time. | |
3/12/2025 | Section 232 | 9903.85.08 | 25% | ALL | Derivative aluminum products, including hinges, fittings, castors, parts of fans and heaters, semiconductor components, as well as certain furniture and sporting goods (refer to the provided link for specific HTS classifications). | There is no exclusion application process available at this time. | |
3/12/2025 | Section 232 | 9903.85.09 | 25% | ALL | Summary of 9903.81.90 and 9903.81.91, where the melt and pour processes occur in the United States. | There is no exclusion application process available at this time. | |
3/4/2025 | IEEPA | 9903.01.24 | 20% | CN & HK | The order replaces the 2/5/25 IEEPA 10% with a 20% rate. | No exclusion application process is available. • 9903.01.21: Donations of food, clothing, and medicine to relieve human suffering. • 9903.01.22: Informational materials (publications, posters, tapes, etc.). • 9903.01.23: Goods exported prior to 2/1/25 and arriving before 3/7/25. | |
3/4/2025 — Suspended | IEEPA | 9903.01.10 (25%) / 9901.01.13 (Energy, 10%) | 25% (10% Energy & Energy Products) | CA | A 10% ad valorem duty is applied to all products, including energy products, in addition to other duties and taxes. | As of 3/6, a 30-day pause is applied to all USMCA-qualified goods, with a reduction to 10% for non-USMCA-qualified potash. • 9903.01.11: Donations of food, clothing, and medicine to relieve human suffering. • 9903.01.12: Informational materials (publications, posters, tapes, etc.). • 9903.01.13: Energy and products subject to a 10% duty. • 9903.01.14: USMCA-qualified goods from Canada. • 9903.01.15: Potash from Canada that does not qualify for USMCA. | |
3/4/2025 — Suspended | IEEPA | 9903.01.01 | 25% | MX | An ad valorem duty is placed on all products, in addition to other duties and taxes. | As of 3/6, a 30-day pause is applied to all USMCA-qualified goods, with a reduction to 10% for non-USMCA-qualified potash. • 9903.01.02: Donations of food, clothing, and medicine to relieve human suffering. • 9903.01.03: Informational materials (publications, posters, tapes, etc.). • 9903.01.04: USMCA-qualified goods from Mexico. • 9903.01.05: Potash from Mexico that does not qualify for USMCA. | |
2/5/25 — Expiring 3/6/25 | IEEPA | 9903.01.20 | 10% (Expiring) | CN & HK | A 10% tariff is applied to all commodities. Ad valorem, in addition to other duties and taxes. The tariff is set to expire on 3/6 and will increase to 20% thereafter. | No exclusion application process is available. • 9903.01.21: Donations of food, clothing, and medicine to relieve human suffering. • 9903.01.22: Informational materials (publications, posters, tapes, etc.). • 9903.01.23: Goods exported prior to 2/1/25 and arriving before 3/7/25. |
Definitions:
IEEPA (International Emergency Economic Powers Act): Invoked citing national emergency due to drug activity, unfair trade practices, and immigration concerns (Mexico and Canada).
The Trade Expansion Act of 1962—Section 232: The importation of identified items presents a risk to national security, impacting the ability to maintain independence in steel, aluminum, and other critical commodities.
Reciprocal Tariffs: Invoked under the International Economic Powers Act and the National Emergencies Act to address trade practices that contribute to large and persistent annual U.S. goods trade deficits.
China Section 301 Tariffs Updates
In 2018, the U.S. imposed three rounds of tariffs on more than $250 billion worth of Chinese goods after its Section 301 investigation determined that China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation were unreasonable and discriminatory. The duties of up to 25% cover a wide range of products, from handbags to railway equipment.
On August 1, 2019, President Trump announced he will impose an additional 10% duty on the $300 billion, List 4 goods beginning September 1, 2019.
On August 13, 2019 the USTR delayed some of the additional tariffs on the proposed List 4 until December 15, 2019, List 4B, and removed some items from the list. However, many items will remain subject to the additional duties on September 1, List 4A.
Summary of Section 301 Tariffs
| List No. | Covered Products | Additional Tariff Rate | Effective Date |
| List 1 | $34 Billion
818 HTSUS Subheadings |
25% Increased to 30% |
July 6, 2018
October 15, 2019 (postponed from Oct. 1) |
| List 2 | $16 Billion
284 HTSUS Subheadings |
25% Increased to 30% |
August 23, 2018
October 15, 2019 (postponed from Oct. 1) |
| List 3 | $200 Billion
5,745 HTSUS Subheadings |
10% Increased to 25% Increased to 30% |
September 28, 2018
May 9, 2019 October 15, 2019 (postponed from Oct. 1) |
| List 4 | $300 Billion
3,805 HTSUS Subheadings |
10% | September 1, 2019 |
| List 4A | ~$120 Billion |
15% 7.5%
|
September 1, 2019
February 14, 2020 |
| List 4B | ~$180 Billion |
15% |
December 15, 2019 |
The USTR has made technical amendments to Lists 3, 4A, and 4B to relieve issues of double Section 301 tariffs on some goods. Effective September 24, 2019, the Section 301 additional tariff will not be imposed on goods classified under any of 39 subheadings “if the applied rate of duty for an entry is derived from another subheading and if the entry, for this reason, already is subject to the additional tariff.” In other words, if a component of a good in one of these subheadings is subject to the Section 301 tariff, the good itself will not be subject to that tariff as well.
